Policy on Corruption, Bribery & Fraud

TSE is a third-generation, family-owned company with a strong moral compass. We take our business ethics seriously. To that end, we have developed a Policy on Corruption, Bribery & Fraud with which all TSE employees, business partners, and vendors must comply. Click here to download a copy of our Policy.

Business Partners, Public Officials and Other Representatives.

TSE expects our suppliers and service providers to respect our ethical standards and to act accordingly. We make decisions within the bounds of applicable laws, standards and norms. We are honest and forthright in our dealings with others and obey all applicable laws and regulations regarding fraud, bribery and corruption. We seek to avoid even the appearance of a conflict of interest.

Accepting and Granting of Incentives, Gifts and Favors.

We recognize the need to avoid even the appearance of a conflict between our personal interests and the interests of TSE. We acknowledge our responsibility to ensure that no personal dependencies, obligations or commitments arise. We may not permit ourselves to be influenced in our business decisions and actions by either gifts or any other type of benefit or incentive. Giving or accepting such gifts could put TSE at legal risk, while undermining our customer relationships and reputation.

To this end, no TSE employee may, in the course of their business activity, either directly or indirectly, demand, accept, offer or grant incentives or rewards that would be unethical. This applies with respect to individuals, companies and also public institutions. No inducements may be offered or granted to any holder of public office, either at home or abroad. This applies to all types of favors, benefits, gifts and payment, or any other consideration. The only recognized exception is that of generally accepted, customary, occasional, or promotional gifts of small value, in keeping with local mores and customers. Also permitted are acts of hospitality and other favors provided they are legally permissible and of verifiable small value.

If any employee has the even the slightest concern as to whether offering a gift or favor could influence a decision, they must ask the recipient to have acceptance approved by the latter’s supervisor. If the recipient refuses to do this, this is an indication that they themselves find the gift inappropriate. TSE employees are likewise required to obtain approval from their supervisor for the acceptance of gifts or favors where any doubts as to their propriety exist.

Bribery and Improper Business Dealings.

In most countries, bribery is illegal and subject to criminal prosecution and penalties, not to mention loss of reputation and civil penalties. Bribery also undermines fair trade and fair market competition. TSE’s goal is to win customers with our products, not through illegal and unfair means.

Therefore, any personal payment, bribe, kickback or similar consideration received by TSE employees, or any offering of personal payments, bribe or similar, by TSE employees to customers, suppliers or other third parties doing business with TSE, is strictly prohibited. This prohibition to offer or receive such payments extends even when such practices are tacitly condoned locally.

TSE employees must report the offer of any improper payment to their supervisor immediately. For the avoidance of doubt, improper payments, bribes or similar includes any and all benefits, including cash, cash equivalents, any valuable services or other benefits of value, that are wrongfully offered to the employee, his family, friends or relatives.

Money Laundering.

No employee shall, either alone or in concert with others, perform any activities that violate domestic or foreign regulations governing money laundering. In the event of doubts as to the propriety of transactions that involve the transfer of cash, TSE’s Corporate Counsel or Chief Financial Officer should be consulted at an early stage.

Market and Competitive Behavior.

TSE and its employees are committed to fair competition and must comply with the antitrust and fair competition laws of the countries in which TSE conducts business. When doubt arises, TSE’s Corporate Counsel should be consulted at an early stage. Certain relationships may pose a problem:

Dealings with Competitors.

Agreements with competitors and coordinated behavior aimed at or causing a restraint or limitation on competition are forbidden. These include agreements to fix or set prices, quotations, terms and conditions of sale, production or sales quotas, as well as the allocation of customers, territories or markets. Likewise, any coordinated behavior arising from, for example, informal talks or “side agreements” aimed at or intended to restrain trade are prohibited.

In discussions with competitors, we must ensure that we not pass on or receive any information that would allow conclusions to be drawn about current or future market behavior. Thus, Corporate Counsel should always be consulted prior to engaging in a joint activity that involves communications with competitors. Current or future information regarding price, margins, costs, market share, internal proprietary practices, sales terms and specific customer or vendor information should not be obtained from or exchanged with a competitor.

Customer Relationships.

Relationships with our customers and suppliers are governed by a number of legal regulations relating to fair competition. In accordance with these laws and regulations, TSE employees will not act in any way that would restrict a customer’s pricing freedom or interfere with supply relationships with their business partners.

Trade and Professional Meetings.

While attendance at and participation in such meetings on behalf of TSE may be important to further corporate objectives, attendance at such meetings can problematic. Such attendance may present a potential antitrust/fair competition risk due to contacts with competitors during the course of the meeting. TSE employees may attend only meetings of legitimate trade and professional associations, conducted for proper business purposes. Any comparative information supplied must be in full compliance with applicable laws and regulations. When in doubt, consult Corporate Counsel.